Whether you're a cryptoasset business managing transaction alerts or a traditional financial institution with VASP correspondent relationships, the UK's May 26 Regulation 17A designations create obligations your existing compliance program may not be configured to meet.
This isn't a standard sanctions designation. For the first time, banking-style sanctions have been applied directly to a cryptoasset exchange, meaning if the sanctioned exchange appears anywhere in a transaction, not just as your direct counterparty, you may have an obligation to freeze funds, block the transaction and report to OFSI. This includes businesses that have never held cryptoassets or dealt with a cryptoasset exchange directly.
What you'll learn
If you're a VASP or crypto business:
- How to reconfigure screening
- Run your lookback
- Route your reporting correctly
- Build your reasonable steps to defense before OFSI asks
If you're a bank or payment firm:
- How to assess your VASP correspondent relationships
- Close the customer payment monitoring gap
- Build a consolidated cross-jurisdictional cryptoasset sanctions response.
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